THE MODEL
Bravemarket seeks to be the best place to perform for investment, advisory and technology professionals. We strive for professionals to be more successful here than anywhere else. In order to do so, our operating model is based on independence and trust. We offer portfolio managers and senior advisors the autonomy and responsibility to manage their own teams and investment and advisory processes. We support teams through access to, financing, liquidity, data, research, industry experts, and powerful connections as well as execution across global markets and asset classes..
We offer proprietary, customizable tools and technology all designed to generate exclusive insights and provide continuing education for our investment and institutional advisory professionals. We continually maintain and enhance our operating system, providing the resources, technology, and infrastructure, adaptable to the changing needs of our teams and our clients. We want our investment and institutional advisory professionals around the globe to focus on investing and creating impact, not on operations.
Within Bravemarket and its network of independent investment managers and firms, we run on collaboration and respect. Teams work together to share trade ideas, identify and address risks, build tools, and explore new opportunities. Our people include world-class fund managers, investment bankers, management consultants, mathematicians, computer scientists, physicists, economists, analysts, business-builders, software engineers, and system architects relying on specialized trading, operational, and compliance expertise developed over 30 years.
RESPONSIBLE AUTONOMOUS EXPERTS
Our proprietary model of self-governing, responsible, autonomous experts (the “Model”) ensures that the Firm is always greater than the sum of its parts. Our Model empowers people to take an ownership approach, to operate as leaders and entrepreneurs, and to pursue complex investments and engagements. We believe this drives excellence. The Model enables our people and partners to achieve more together and to foster active collaboration across the Firm to generate superior investments, performance, and outcomes. The Model unites the different perspectives and independent thinking greatly valued in the Firm..
I.
CODE OF BUSINESS CONDUCT AND ETHICS
Bravemarket Code of Business Conduct and Ethics (the “Code”) embodies the commitment of the Firm to conduct business in accordance with all applicable governmental rules and regulations and to promote honest and ethical conduct. This Code applies to all officers and employees of the Firm and its subsidiaries, its associates, its affiliates, its partners and members of the Board of Directors of the Firm (the “Board”) (such persons, the “Covered Persons”), each of whom is expected to adhere to the principles and procedures set forth in the Code that apply to them.
The Firm also has separate, specific policies and procedures to follow under particular circumstances or in specific areas of its business. Failure to comply with this Code, or to report a violation, may result in disciplinary actions, including warnings, suspensions, termination of employment or strategic arrangements or such other actions as may be appropriate under the circumstances. The Code is intended to meet the standards of a code of ethics under the Sarbanes-Oxley Act of 2002, as amended, and the standards of a code of business conduct and ethics under the listing standards of The New York Stock Exchange. This Code is a statement of certain fundamental principles and policies and procedures that govern the Covered Persons in the conduct of the Firm’s business. It is not intended to and does not create any rights in any Covered Person, supplier, borrower, competitor, stockholder or any other person or entity.
II.
COMPLIANCE WITH LAWS, RULES AND REGULATIONS
Obeying the law, both in letter and in spirit, is the foundation on which the Firm’s ethical standards are built. All Covered Persons must respect and obey the laws of the cities, states and countries in which we operate. Although not all employees are expected to know the details of these laws, it is important to know enough to determine when to seek advice from supervisors, managers or other appropriate personnel. Covered Persons should strive to identify and raise potential issues before they lead to problems and should ask about the application of this Code whenever in doubt. Any questions relating to how these policies should be interpreted or applied should be addressed to the Chief Compliance Officer.
INSIDER TRADING: You are prohibited by Firm policy and by law from buying or selling publicly traded securities for any purpose at a time when you are in possession of “material nonpublic information.” This conduct is known as “insider trading.” If you have any question about whether a particular transaction may constitute insider trading and what you need to do in such case, you should consult the Firm’s Insider Trading Policy, which has been provided to you (and is available upon request to the Chief Compliance Officer).
III.
CONFIDENTIALITY AND FAIR DEALING
In carrying out the Firm’s business, Covered Persons often learn confidential or proprietary information about the Firm, its clients, its prospective clients or other third parties. Covered Persons must maintain the confidentiality of all information entrusted to them except when disclosure is authorized or legally mandated. Confidential or proprietary information includes, among other things, any non-public information concerning the Firm, including its businesses, financial performance, results or prospects, and any non-public information provided by a third party with the expectation that the information will be kept confidential and used solely for the business purpose for which it was conveyed. The obligation to protect confidential information does not end when a Covered Person leaves the Firm.
The Firm is committed to maintaining the highest legal and ethical standards in the conduct of its business. Meeting this commitment is the responsibility of the Firm and each and every one of our Covered Persons. Each Covered Person should endeavor to deal fairly with the Firm’s investors, clients, partners, suppliers, service providers, competitors and employees. No officer, director or employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any unfair dealing practice.
Bravemarket’s success has been driven by its first-class mosaic of diverse individuals bringing their own strengths, expertise, and experiences unified by the Model and the Code.
